Subject: File No. S7-15-10
From: John M Lynch
Affiliation: Financial Advisor

October 22, 2010

The Sec should eliminate 12b1 fees in wrap fee accounts . For 3 years I have been on a crusade with my broker dealer to rebate 12b1 fees in IRA wrap fee accounts with no success. An example of how harmful this can be to both clients and advisors is with American Funds. Three years ago American funds came out with a f2 share class designed specifically for wrap fee accounts.(no 12b1 fee) Wells Fargo/ Wachovia refuses to allow the share class on their platform. The only share class they allow is the F1 where Wells pockets the 12b1 fee in adition to the wrap fee the client pays. As an advisor I should not be forced to buy a higher expense share class when a lower expense share class is available. If a firm needs more revenue they should raise admin fee etc and fully disclose those fee increases to the client. A 12b1 fee should not be used to fund the Amin costs of a Wrap fee program. A 12b1 fee is a commission. The client believes they are in a commission free account. The behind the scenes fees should be eliminated as much as possible. I would be glad to discuss this further if you think it would be beneficial.